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ISM-2093 policy ASD Information Security Manual (ISM)

Restrict Access to AI Data with Role-Based Controls

Access to sensitive AI data is restricted using roles to ensure only authorised personnel can view it.

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Plain language

This control ensures that only the right people can access sensitive data used in artificial intelligence systems by assigning different roles to different people. If not done, there’s a risk of unauthorised people gaining access, which could lead to data breaches, misuse of information, or even financial and reputational damage to your organisation.

Framework

ASD Information Security Manual (ISM)

Control effect

Preventative

Classifications

NC, OS, P, S, TS

ISM last updated

Nov 2025

Control Stack last updated

19 Mar 2026

E8 maturity levels

N/A

Official control statement

Role-based access controls are implemented for artificial intelligence applications to restrict access to sensitive data.
policy ASD Information Security Manual (ISM) ISM-2093
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Why it matters

Without role-based access, unauthorised access to AI data can lead to breaches, data misuse, and significant financial or reputational harm.

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Operational notes

Regularly review and update roles to ensure access aligns with current duties, preventing data exposure through outdated permissions.

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Implementation tips

  • Business owners should identify the types of sensitive data that their AI systems use and establish a list of people who need access to this information. This involves considering who within the organisation relies on this data to perform their job effectively.
  • Managers should define clear roles and responsibilities for team members who need access to AI data. They can do this by mapping out job functions and associating them with different levels of access according to the sensitivity of the data involved.
  • The IT team should set up the technical system to match these roles with their respective access permissions. This means using software that supports role-based access controls and configuring it to allow or deny access based on each user's role.
  • The Human Resources (HR) team should regularly review and update the access list as people's roles within the organisation change. This could be incorporated into routine checks such as staff performance reviews or changes in job responsibilities.
  • Managers should provide training for all staff about the importance of protecting sensitive AI data and how role-based controls help with this. This can be done through workshops or e-learning modules that explain how data is managed and why certain people have different levels of access.
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Audit / evidence tips

  • AskThe list of roles and associated access levels: Ensure there is a document or system record specifying which roles have access to what data GoodA clear, updated list showing role names, data access details, and rationale
  • AskAn access control policy document: Request the formal policy that explains how access to AI data is managed within the organisation GoodIncludes defined roles, data classification, and enforcement procedures all documented and approved
  • AskAccess logs: Ensure there is a record of who accessed certain AI data and when. Check these logs to see if access is appropriately restricted to authorised roles GoodConsistent records showing access correlating with authorised job roles
  • AskEvidence of staff training on role-based access: Request records showing that staff involved with AI data have received appropriate training
  • AskA review schedule and records: Request information on how often and how access permissions are reviewed and updated
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Cross-framework mappings

How ISM-2093 relates to controls across ISO/IEC 27001, ISO/IEC 42001, Essential Eight, and ASD ISM.

ISO 27001

Control Notes Details
layers Partially meets (2) expand_less
Annex A 5.15 ISM-2093 requires organisations to implement RBAC in AI applications to prevent unauthorised access to sensitive AI data
Annex A 8.3 ISM-2093 requires RBAC for AI applications to restrict access to sensitive AI data
sync_alt Partially overlaps (1) expand_less
Annex A 5.18 ISM-2093 requires RBAC enforcement in AI applications so only authorised roles can access sensitive AI data
handshake Supports (1) expand_less
Annex A 5.3 Annex A 5.3 requires organisations to segregate conflicting responsibilities to reduce opportunities for misuse, fraud or error

E8

Control Notes Details
sync_alt Partially overlaps (1) expand_less
E8-RA-ML3.1 ISM-2093 requires role-based access controls (RBAC) for AI applications to restrict access to sensitive AI data to authorised personnel

These mappings show relationships between controls across frameworks. They do not imply full equivalence or certification.

Mapping detail

Mapping

Direction

Controls